New Local Plan: Spatial Options Document 2021

Support

Representation ID: 41401

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

MOH support the Draft Vision, welcoming in particular the Council’s wish to plan positively and to set a longer-term vision to 2050. Setting a longer-term vision would be consistent with paragraph 22 of the NPPF, but if this vision is to be achieved, then the new plan must be up-to-date and fit for purpose. It is vital therefore that the need for growth is embraced positively and that the most sustainable and deliverable options to achieve this are pursued so that the needs of the area are fully met, including any shortfall in past delivery, and where the need to travel is reduced and the benefits for both existing and future residents are maximised. Recent experience has shown that a number of neighbouring
authorities (e.g Castle Point) will struggle to meet their needs in full, and therefore, opportunities to assist them should also be explored upfront at an early stage and provision made accordingly to ensure that Rochford’s new plan can be found sound at the earliest opportunity.

Support

Representation ID: 41402

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

MOH support the adoption of a set of settlement-based visions. The work undertaken by the Council as
part of the Role and Hierarchy Settlement Study shows the extent to which the role and function of the
settlements in the district differ and the adoption of settlement-based visions would enable this individuality to be reflected and the strategy for each to be appropriately tailored. Indeed, in a primarily rural authority like Rochford, each settlement performs a different role for its population and hinterland and the capacity it has to accommodate sustainable new growth will vary according to that role or other physical or policy constraints. It is considered that visions that reflect and respond to these individualities would provide greater certainty regarding the role each settlement is expected to perform moving forward enabling the needs of the district to be met.

Support

Representation ID: 41403

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

MOH agree with the strategic priorities and objectives identified.

Comment

Representation ID: 41404

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth Scenarios
3.4 The Spatial Options document sets out a number of growth scenarios but does not seek a response on
any of these explaining at page 46 that there remains significant work to be done through the planmaking process to develop a strategy that successfully balances the district’s need to grow with the need to safeguard the natural and built environment. MOH accepts that further work needs to be undertaken but would like to make the following observations.
3.5 The recognition that Rochford must grow sufficiently over the plan period to ensure that the needs of existing and future communities are met, and that the younger population is encouraged to stay in the district as a result of an increased supply of new and affordable housing, job opportunities and infrastructure is very much welcomed by MOH.
3.6 Planning for the right amount of growth is a balance and there is a need to take account of both the enormous economic advantages that ensue from such growth, as well as the capacity of infrastructure and the environment to accommodate it. It is clear however that there are a number of structural demographic, housing and economic challenges in Rochford that must be addressed if the Council’s spatial vision is to be achieved, not least the increasing elderly population, increasing ratio of local house prices to earnings leading to the out-migration of the younger population in search of more affordable housing and low job density resulting in a reliance on out-commuting of residents and the
consequential leakage of spending and investment. It is imperative that the Council adopt a positive and proactive approach towards securing a scale of growth that would adequately meet the identified needs of the area such that it is possible to begin redressing these serious issues and create the place that its own proposed strategic vision envisages.
3.7 Figure 15 sets out three growth scenarios – the current trajectory, the standard methodology and the
standard methodology + 50% buffer. The NPPF obliges Council’s to meet their identified needs based as a minimum on the current standard method. Growth based upon the current trajectory would fall some considerable way short of meeting this and recognition by the Council that a plan based upon this would be likely to be found unsound, is welcomed. Any housing requirement must as a minimum secure the local housing need, but for the reasons set out below, MOH consider that there exist sound reasons in the case of Rochford to plan for a requirement beyond this.
3.8 The Housing Topic Paper 2021 explains at paragraph 7.1 that between April 2011 and April 2021 there were 2,048 housing completions, which is ahead of the phased target set out in the adopted Core Strategy for this point in the plan period. That may be so, but as the Core Strategy was adopted in 2011 and now being more than five years old the Council is required to use a Local Housing Need (LHN) figure calculated using the standard methodology.
3.9 The district’s annual LHN figure is 360 homes compared to the annual requirement set by the Core
Strategy of 250 homes. It is notable from the Council’s evidence base that over the last 10 years delivery has fallen short of the existing annual requirement, with paragraph 10.6 of the Housing Topic Paper noting that the historic rate of delivery is 227 homes per annum. Accordingly, with delivery lagging behind the existing lower target, a significant uplift in annual completions (+60%) will be required if the LHN is to be met. It would also therefore fall someway short of any figure generated
from the LHN. Past patterns of delivery have resulted in an increasing affordability gap and every effort
must be made moving forward to rectify this and ensure that these trends do not persist by setting a housing requirement that provides adequately for all identified needs and allocating a range of sites that provide for a sufficient and flexible supply.

3.10 It is agreed that the current standard method generates a minimum LHN figure of circa 360 per annum
or a total requirement of 7,200 homes over the next 20 years. MOH also note and welcome the Council’s recognition that this figure should be used only as a starting point from which to work. This is essential if there is to be sufficient flexibility built-in to the new plan to ensure it can respond and deliver to meet that need and to make up for the pattern of under delivery against current targets that has prevailed in recent years.
3.11 The standard methodology is a ‘blunt instrument’ that provides an indication of quantity but makes little
in the way of qualitative adjustment. The methodology determines only “the minimum number of homes needed“ from which it may well be appropriate to apply an uplift. The use of the standard methodology either on its own or without full assessment of all factors affecting housing need in a particular authority is unlikely therefore to meet the full needs of a district, and that is particularly so in Rochford. As noted above, the Council’s evidence base shows that since 2011 delivery has fallen short
of the local plan annual target, which is 30% lower than the minimum standard method figure. Historic levels of delivery have, like in the rest of South Essex, resulted in an increasing affordability gap with the South Essex Strategic Housing Market Assessment (SHMAA) identifying a significant level of unmet and likely future need for affordable homes, which in relation to Rochford itself, equates to some 268 new affordable homes per year – a figure which significantly exceeds the existing adopted requirement and equates to 60% of the LHN figure.
3.12 The need to respond proactively to the widening affordability gap in the district, as well as addressing
its affordable housing needs, is justification enough to build in greater flexibility in supply. As the majority of affordable housing in the district is secured and delivered as part of larger housing schemes in accordance with policy requirements and viability considerations, the only realistic way to increase housing delivery is by increasing the overall delivery of housing by setting a higher requirement. Given the widening affordability gaps in the district and the need to build-in flexibility in supply, MOH would urge the Council to give serious consideration to going beyond the LHN when setting the future housing
target. Indeed, it is clear from the Council’s own evidence base that to use the standard methodology figure as a housing requirement rather than as a starting point for assessment would mean that the plan would fail to make adequate provision for local identified needs.
3.13 The recognition of the role that Rochford could play in assisting neighbouring authorities by accommodating some of their unmet need is further welcomed by MOH. The difficulties that some of the authorities in South Essex face in terms of meeting their own needs is well documented and while Rochford has its own constraints, with a good supply of available land (as evidenced by the UCS and HELAA), one of the lowest LHN figures of the South Essex authorities and close connections with other
settlements across boundaries it is well placed to positively assist its neighbours and contribute to realising growth in the Thames Estuary. Such an approach is not only encouraged but is expected by paragraph 61 of the NPPF.
3.14 With the above in mind, MOH firmly support the proposition that the new plan make provision for an
appropriate buffer on top of the LHN figure in order to ensure that a continuous and responsive supply of housing land comes forward, that affordable needs are met and housing suitable to an ageing population is provided, and that assistance be offered to neighbouring authorities who may experience greater difficulties in providing for their needs. These significant long-term positive effects are recognised by the Integrated Impact Assessment (IIA), which concluded that The medium and higher growth options provide a greater opportunity to deliver new and improved community infrastructure in
the district as well as deliver a greater number of affordable homes and a mix of dwelling sizes, types
and tenures. This includes the delivery of suitable homes for an ageing population, which is a particular issue for the district. The higher growth option in particular is more likely to achieve this as well as improve cross-boundary links between communities, such as Southend”
However, any uplift to ‘future proof’ the new plan should be applied only once the full extent of housing need has been identified and provided for.
3.15 There is no evidence that the housing supply cannot be increased to meet a higher requirement in order to provide the need for flexibility. Indeed, it is evident from the Urban Capacity Study and HELAA that there is no shortage of available land capable of delivering development across the district. While providing this level of growth will require difficult decisions to be made, not least in relation to the release of Green Belt land, the challenges faced by Rochford are by no means unique to it and are being grappled with and proactively dealt with by a number of other local authorities across the
country. It must in any event be kept in mind that the environmental dimension is only one of the three
strands of sustainable development, and it may well be that the economic and social benefits arising from development, for example the ability to help meet the worsening affordability gap identified in the consultation document, outweigh harm to the environmental strand. We would urge the Council to keep an open mind in this regard.

Comment

Representation ID: 41406

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

The consultation document sets out four options for delivering the new homes needed in the district.
These are:
• Strategy Option 1: Urban Intensification
• Strategy Option 2: Urban Extensions
» Option 2a: Focused on main towns
» Option 2b: Dispersed to all settlements based on Settlement Hierarchy
• Strategy Option 3: Concentrated growth
» Option 3a: Focused west of Rayleigh
» Option 3b: Focused north of Southend
» Option 3c: Focused east of Rochford
• Strategy Option 4: Balanced Combination
Option 1 proposes that best use be made of existing planned developments, previously developed land and other underutilised land and a more permissive approach be taken to allowing higher densities in urban areas. While such an approach is a key requisite of national policy and by implication a key component of any development strategy, it would not enable the Council to meet its needs in full even if all capacity identified by the Urban Capacity Study were to be realised. The reality is that previously developed sites are more difficult to develop than greenfield ones generally being subject to greater constraints and viability considerations such that their delivery is often slower than expected. As a
consequence, this does not represent a reasonable option for consideration on its own but rather should form the baseline of any other option/s.
Option 2 would spread development across a range of development sites adjoining existing towns and
villages. The main towns are the most sustainable locations for new growth with optimum access to
facilities and services. This option would offer the best balance between meeting the majority of needs where they arise, securing the most sustainable patterns of growth by locating development where it currently exists and can support and enhance existing infrastructure and ensure a rolling programme of delivery via the allocation of a greater range of sites in different ownerships. This option would result in the release of Green Belt land, but the reality is that any option pursued will necessitate this if the identified needs of the district are to be met. However, the land around the edges of settlements is
likely to be less sensitive in terms of the contribution it makes to Green Belt purposes and landscape character and is more likely to have a greater capacity to accommodate new development by reason of its relationship with existing built form.
Option 3 proposes concentrated growth and the creation of new neighbourhoods in up to three locations. This option is considered by the Interim SA to perform marginally better than the other options, primarily due to the scale of economies and the ability to deliver new infrastructure and mitigation alongside growth. However, the precise location of these new neighbourhoods is currently unknown and has not been the subject of any thorough testing. Only when a particular location is
identified can the extent of any impacts or benefits be robustly assessed. This option would also result
in the substantial redrawing of the green belt. Whilst meeting the needs of the district will require Green Belt release regardless of the option pursued, Option 3 would necessitate the release of land in the middle of the Green Belt rather than around the edges of existing settlements where land is more likely to be damaged or compromised by existing built form and its contribution to the purposes of the Green Belt are likely to be reduced.
Under Option 3 the neighbourhoods would comprise at least 1,500 new homes and therefore a large proportion of additional growth for the plan period would be focussed in these. In this context, it represents an ‘eggs all in one basket’ option that would offer some benefits, but it would fail to meet the needs of the district’s residents where they exist compounding existing affordability and delivery issues or deliver much needed infrastructure improvements where residents currently live. A matter noted by the IIA, which states that “Any development delays, or failure to bring forward development at the location has repercussions for housing land supply and the effectiveness of the plan. This could inevitably result in a lack of housing land supply and speculative development. Furthermore, the
concentration of growth at one location means that development benefits will not be spread across the
district, and existing residents are less likely to see new homes, including affordable homes, or infrastructure improvements in their areas”
The delivery of new neighbourhoods/settlements is, by nature, slow and cumbersome. They bring with them benefits associated with critical mass but on their own cannot provide a quick or flexible response to change or maintain the rolling programme of delivery throughout the plan period that NPPF paragraphs 60-80 expect. Indeed, their scale, complexity and up-front infrastructure costs means they are not always easy to kick-start and once up and running, there is a need to be realistic about how
quickly they deliver homes. To avoid this, not only must the assumptions that local plans make about how quickly sites deliver be realistic and justified, but they must also allocate more sites rather than less that can support a good mix of types and sizes of new home to ensure supply is maintained throughout the plan period. New neighbourhoods/settlements do have merit, but only where it forms part of a wider strategy that distributes growth elsewhere to meet all needs in a timely manner and provides an effective means of reducing travel by car. In this context, if the Council were to pursue Option 3 for its specific benefits, it must be in conjunction with significant growth elsewhere in other sustainable locations e.g Option 2.
Option 4 proposes the dispersal of development across the district via a combination of Options 1-3.
While MOH consider that Option 2 and the allocation of land around the main towns represents the most deliverable and sustainable means of accommodating housing growth, it accepts that a strategy based on Option 4 could have some merit in terms of delivering new infrastructure and providing growth to support existing rural services and facilities. However, should the Council opt to pursue this option then careful consideration must be given to the appropriate balance between each of the individual options it comprises to ensure that the supply of housing is maintained and growth is not spread too widely and in a manner that does not align fully with the principles of sustainable
development so far as it would result in growth in locations more reliant on the car, would not provide
sufficient growth to support enhanced infrastructure and result in the loss of more valuable agricultural land or land subject to a greater number of sensitivities (Green Belt, landscape, protected habitat, proximity to wildlife sites etc).
It is clear that whichever option the council ultimately decides to pursue, it should place great weight
on the identification of a wide range of sites which are capable of delivering a significant number and mix of homes and community infrastructure in the most sustainable locations, especially in Rayleigh.

Comment

Representation ID: 41408

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

As a general point and as already explained earlier in these representations, the challenges faced in delivering not just enough, but also the right type of housing over the plan period, due to low housing completions, changing demographics and increasing affordability issues are such that the new plan must seek as a priority to proactively deliver a strategy that will enable a boost in the delivery of new housing going forward. It is for this reason MOH consider that if the plan is to succeed in this
obligation, then a housing requirement exceeding that generated by the standard methodology is a must.

It will continue to be the case that the majority of new housing will be provided by the private sector, and therefore, policies that are intended to secure the provision of the right type and tenure of housing must be cast with sufficient flexibility to ensure that development remains viable to the market. Every site and every development is different and an approach that seeks to apply standard non-negotiable mix requirements is likely to be counterproductive regardless of the positive change it is seeking to secure. Accordingly, MOH consider that in relation to the options for addressing housing needs set out at page 78 of the consultation document, an approach based on Option 2, alongside Options 5-7, offers the best prospect of striking this balance and should be pursued.

Support

Representation ID: 41409

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

The conclusions drawn by the consultation paper and accompanying Sustainable Settlements Study are noted and the recognition of Rayleigh’s relative sustainability and resultant identification as a Tier 1 settlement is supported.
Given the need to promote sustainable patterns of development, it is inevitable that the majority of growth should be directed to those settlements highest in the hierarchy. As the only Tier 1 settlement, the main town in the district and “the principal centre of services for over half the District’s residents and businesses, including large communities beyond its own boundaries”, Rayleigh should be a major focus for this. The conclusion of the Complete Communities Topic Paper 2021 that Rayleigh could sustain significant growth to improve completeness is welcomed by MOH in this respect.

MOH agree with the vision for Rayleigh, supporting in particular the wish to see the creation of a town that provides for a diverse range of housing and job opportunities, meeting the needs of all in the community. If it is to achieve this then the scale of the growth required, together with the need to ensure a rolling programme of delivery, is such that the plan will need to make provision for a mix of development sites. Indeed, the Council will need to ensure that it identifies and allocates a variety of differently sized sites, especially those between 100-150 dwellings that are of a scale that makes them able to deliver quickly and make a meaningful contribution to boosting the supply of market and affordable homes whilst supporting new and improved infrastructure.

Support

Representation ID: 41428

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

MOH welcome the identification of all ‘promoted’ sites on Figure 44 and the invitation to comment on these.
MOH has an interest in one of the promoted sites - Site Ref: CFS077 – Land to the north of Great Wheatley Road, Rayleigh and provides a response in relation to that site below, including the contribution it could make to the completeness of Rayleigh.

LAND TO THE NORTH OF GREAT WHEATLEY ROAD, RAYLEIGH
The Site
The site, which extends to 10.97ha, and is located to the south west of Rayleigh. The location and extent of the site is identified on the site location plan below, a full-sized version of which is contained at Enclosure 1:
Red Line Location Plan
[SEE ATTACHED DOCUMENT FOR IMAGE]
The site comprises two medium sized arable fields, a pocket of woodland to the south east and a small tract of pastoral land which extends towards Great Wheatley Road to the south. The topography of the site is undulating, with a distinct ridge of higher ground running northwest-southeast across the two arable fields and with the land rising to the south and east within the tract of pastoral land to the south.
Existing residential development abuts the site to the north, east and south with further fields extending to the west. Great Wheatley Farm, comprising three Grade II listed buildings (Great Wheatley Farmhouse and two barns) is located directly to the south west of the site, and a large scale substation is located to the north. A railway line which broadly runs east to west is located approximately 200m to the north of the site which further reduces the perceived tranquillity of the site. A network of major road corridors is located within the site’s localised context to the west, comprising the A127 Southend
Arterial Road, the A1245, and the A130.

Lying immediately on the edge of the existing built-up area of Rayleigh and being surrounded on three sides (north, east and south) by existing housing, the site enjoys a high degree of visual and physical containment. It is sustainably located within convenient reach of existing local facilities and services and is according to the ‘Walking Completeness’ mapping located immediately abutting an area with a
good level of walking access (Walking Completeness Score 11-13). Accordingly, MOH remain firmly of the view that the site represents a natural extension to the settlement and a sustainable location for new housing.

Background
The site was submitted in response to the Council’s ‘Call for Sites’ and the Issues and Options Consultation in 2017/18. The latter submission was supported by a Vision Statement and a high-level Initial Masterplan intended to provide an indication as to how the site could be developed taking account of key constraints. Since this time, more detailed technical work has been undertaken and the results of this have been fed into this submission.
The site is identified in the Site Appraisal Paper 2021 as being deliverable subject to policy; the key
policy constraint being its location in the Green Belt. MOH welcome this. As with all other promoted sites the SAP provides an assessment of the site against a series of criteria ranging from 1 (poorest performing) to 5 (best performing). MOH has considered the scoring awarded to the site and would like to make a number of observations on the following criteria/scoring. In some cases, further assessment work has been undertaken to support these observations as noted in the table below:
[SEE SUPPORTING DOCUMENT FOR TABLE]

The Illustrative Masterplan has evolved to reflect this further assessment and an updated Constraints and Opportunities into which the results of that work have been fed. The principal revisions to the masterplan are in relation to landscape and heritage considerations and the manner in which they can positively shape the development of the site. The opportunity has also been taken to further explore pedestrian and cycle connectivity, with routes designed to enable ease of movement between the site and its surroundings incorporated into the layout. With a developable area of 4.7ha, the masterplan, which is shown below, illustrates how a development of circa 150 dwellings could be achieved.
Illustrative Masterplan
[SEE ATTACHED SUPPORTING DOCUMENT]

The Constraints and Opportunities Plan and the Illustrative Masterplan can be found at Enclosures 2
and 3, respectively, and the principal changes made since the last submission can be summarised as
follows:
• A reduction in development footprint in favour of more open space and structure planting.
• Development pulled away from the listed barns and Great Wheatley Farm to the south west.
• Development removed from the strip of land immediately to the east of Great Wheatley Farm.
• Development pulled away from sensitive boundaries.
• Introduction of structure planting onto the ridgeline to assimilate development into the landscape.
• Development blocks and roads following the topography more closely.
• Development amended to reflect updated drainage strategy.
• Potential routes for pedestrian and cycle connections shown.

Response to the Site Appraisal Paper
Critical Drainage
A Flooding and Drainage Note has been produced by MAC, which provides an appraisal of potential flood risk and drainage constraints for the site (Enclosure 4). In accordance with the conclusions of the SAP, it explains that the site is located in Flood Zone 1 and is therefore in an area at a low risk of flooding. In relation to critical drainage, it recognises that the site lies in a critical drainage area but explains how surface and foul water drainage can be delivered on the site such that it does not present any insurmountable constraint to its development.
The surface water flood risk map shows the site is generally at a low or very low risk of surface water
flooding. Given this and the topography of the site, the risk of surface water flooding is considered to be low. However, the site is identified as being in a Critical Drainage Area (CDA) by Essex County Council (ECC). CDAs are described by ECC as ‘small catchments where there is an increased risk of surface water flooding’. The CDA which includes this site covers the whole of Rayleigh and joins with neighbouring CDAs. As such the CDA has not assessed the site-specific surface water flood risk. So far as the surface water flood risk map shows the site is not at risk of surface water flooding, it should not be considered to be within a CDA. Accordingly, the site warranted a score of 3 rather than 2 in the SAP under the heading of ‘Critical Drainage’.
The Flooding and Drainage Note includes a Surface Water Drainage Strategy at Appendix C, which shows how surface water would be attenuated within three detention basins to achieve greenfield equivalent run-off rates and a 40% climate change allowance. It is anticipated that foul water would discharge to Anglian Water’s sewer(s) located within the surrounding highway. Due to the levels on the site, it is likely that a foul water pumping station(s) would be required. The proposed strategy has been taken into account in preparing the Illustrative Masterplan showing that drainage does not pose any constraint to site’s development for housing.

Green Belt Harm
The Green Belt Study concludes that the vast majority of the Green Belt in Rochford continues to serve
the Green Belt purposes well, particularly in terms of maintaining the openness of the countryside. However, the Part 1 Study identified that there are several pockets of Green Belt adjacent to the existing urban edges that make a weaker contribution to the majority of the Green Belt purposes. The site (Site Ref: 77) forming part of Assessment Area 18 alongside land lying to its west between the railway and the A127 (Site Refs: 121 and 55) is identified as one of these. In the Part 2 Study (Table 5.2), the site is identified as making a moderate contribution to Green Belt purposes, compared to Sites
121 and 55 to the west which are considered to make a moderate-high contribution.
The Green Belt Study considers that the site makes a moderate contribution to preventing the sprawl of
Southend-on-Sea and to preventing the merging of towns, and a strong contribution to preventing
encroachment on the countryside. It notes however that the release of the site would have the benefit of creating a more consistent Green Belt boundary with the existing urban edges of Rayleigh to the north and south due to the extent of containment by the urban edge. MOH welcome the recognition in the Green Belt Study of the site’s containment by existing development and the benefit its development could have in providing a more consistent, and therefore defensible, Green Belt boundary, but consider that by reason of this and the relatively modest scale of the site, the contribution it makes to the three referenced Green Belt Purposes has for the reasons set out below been overstated.
• Sprawl: The development of the site would extend the built-up area of Rayleigh beyond its existing boundaries. However, to the north it is bounded by a large sub-station, railway line and extensive residential development beyond, while the southern and eastern boundaries of the site are fully enclosed by properties on Great Wheatley Road, Highmead, Spring Gardens, Poyntens and Burrowsway with the built up are of Rayleigh beyond. By reason of its location in close proximity to the settlement boundary and enclosure by existing built form, particularly to the north and south
which extends well beyond the western extent of the site, the proposed development would appear as a natural extension and would not constitute urban sprawl of the kind that Green Belt policy is intended to prevent. Sprawl of the kind Green Belt Policy is intended to prevent describes unplanned, ad hoc incursions into the countryside. On the contrary, any development on the site would represent a sustainable planned development that would integrate with existing development, create a new defensible boundary to the built-up area and positively respond to an identified economic and social need, site and infrastructure constraints, including the landscape.
• Merging of Neighbouring Towns: The area of Green Belt in which the site falls separates Rayleigh from Thundersley, north and south Benfleet and Basildon to the south and west and Wickford to the north west. These settlements are sufficiently well separated from Rayleigh not to merge if the proposed housing development were approved. In any event the site contributes little to the separation by reason of its small size and enclosed nature and if it were developed the
impression would be little different from that which exists now.
• Encroachment into the Countryside: Being located outside the existing built-up area, the site lies within the countryside, and in this regard, it is accepted that its development would result in an encroachment in this area. The development would result in what is now undeveloped land within the countryside becoming urbanised, but its impact would be moderated by reason of its close relationship to the settlement edge and its containment from existing development to the north,
south and east. As the Landscape and Visual Appraisal (Enclosure 5) explains, the site is not of a particularly high landscape value, is influenced by its urban fringe setting and is well contained by adjoining residential development. It is considered that the extent of mature vegetation within the site’s localised and wider setting would ensure that any impact upon the wider countryside as a result of development would be localised. Therefore, whilst the development of the site would result in the loss of some greenfield agricultural land on the edge of Rayleigh, it would not represent a significant encroachment into the countryside, being contained by the existing urbanising features that are already characterised by the urban edge, and the opportunities that are provided to form a new logical Green Belt boundary along the west of the site through reinforced and new planting.

Harm to the Landscape
The site has been scored 3 against landscape. Curiously, Site 121 lying to the west and in a more
exposed situation further from the settlement boundary, performs better having been scored 4. This scoring neither reflects the location of each site relative to the settlement boundary nor the conclusions of the Landscape Character, Sensitivity & Capacity Study (LCSCS) and needs reconsideration.
The study area for the assessment of landscape sensitivity and capacity includes the character areas (or
parts thereof) identified in the Landscape Character Assessment, that are outside settlement boundaries
within the Green Belt. This should therefore have included Site 77, however, MOH’s land has not been
assessed. This is because the site has been treated as lying within the urban area of Rayleigh (G3 –Rayleigh) rather than within the Woodland Farms & Hills Character Area (D1 – Rawreth) as land lying to the north, south and west, including Site 121, has been – refer to the extract from Figure 2.6 of the LCSCS below. We presume that this is a reflection of the site’s location immediately adjacent to the settlement, physically and visually contained as it is by existing development and woodland, which means that its relationship is with the existing built-up area rather than the countryside to the west.
While the identification of the site by the LCSCS as one that relates to the urban area is welcomed (with the inference being that it has capacity to accommodate development), the consequence of this is that the site (as
one that lies outside the settlement) does not benefit from an assessment of sensitivity or capacity to accommodate development. Had it been assessed we presume it would have been included within the Character Area D1 to the west of Rayleigh alongside Site 121, which the LCSCS (Figure 3.1) considers to have low/medium sensitivity and a medium-high capacity for
development (Figure 3.2). For the reasons explained in the accompanying Landscape and Visual Appraisal (LVA) (Enclosure 5), and in particular the urban nature of three of the site’s four boundaries, it is considered that the site has a high capacity to accommodate development.
On this basis, MOH’s land should at the very least have scored 4 like Site 121 to the west, albeit it is
clear that due to its proximity to and relationship with the settlement edge and its consequential containment, it has a greater capacity to accommodate development.
As the accompanying LVA explains, there would be some localised harm to the site itself as a result of
developing a greenfield site, but that harm would be restricted to the site and its immediate context
reducing substantially within the wider landscape setting. As it explains at paragraph 2.5, other than being an area of undeveloped arable land with internal field boundaries, the components of the majority of the site offer little in the way of landscape value with the established vegetation structure, tree belts and pockets of woodland providing a degree of containment and visual separation from adjoining land uses and road corridors. The result is that the development of the site for housing would be compatible with the localised context and would link with the existing built-up edge of Rayleigh to the north, east
and south, which already forms a notable urbanising feature within the site’s setting to the west, and any proposed development would be seen within this context.
With reference to the Illustrative Masterplan, the LVA explains that it would not introduce any new
components that would appear out of character, dominant or overbearing within the context of the
adjoining streetscene, nor would it breach the current limits to Rayleigh formed by the major road corridors within the site’s localised context. With the retention of all key vegetation other than some limited breaks in the existing vegetation structure required to allow access and the reinforcement of existing tree belts and woodland blocks with additional planting, any new development is capable of being successfully integrated into the receiving landscape.

National Habitats
Manor Oak Homes welcomes the score of 5 given to the site in relation to ‘Impact on Ancient Woodland”, “Impact on International Habitats” and “Impact on Local Habitats”. As regards “Impact on National Habitats”, it is noted that the site is listed as “Moderately Performing” scoring 3 and that this is based purely on distance from a nationally protected habitat site – Thundersley Great
Common SSSI in this case – rather than as a result of any alleged harm.
A note produced by Aspect Ecology is contained at Enclosure 6, which explains that the site is located approximately 660m north of the SSSI and that there are no other nationally protected ecological designations within 2km of the site. The SSSI is identified by Natural England as having a “No identified Condition Threat” risk and is physically separated from the site by existing residential development and roads (including the A127 Southend Arterial Road), such that it is extremely
unlikely to represent any constraint to the proposed allocation and development of the site.

TPO
The Site Appraisal Paper (SAP) awards the site a score of 2 against the heading of TPO given that it
includes one or more trees the subject of Tree Preservation Order (TPO). A note prepared by Aspect Arboriculture is contained at Enclosure 7, which based upon a tree survey and review of available background information, identifies the nature and extent of any arboricultural constraints and provides recommendations on the design principles that should be followed in the preparation of any future scheme. These recommendations have informed the production of a revised Illustrative Masterplan demonstrating that the existence of protected trees on site do not present an
insurmountable constraint to its development.
So far as the trees the subject of TPO are concerned, these comprise a collection of trees along the
northern boundary, and the woodland edge within the southeast extent of site, the coverage of which is illustrated on the Tree Constraints Plan at Enclosure A of the note. The site’s principal trees comprise a parcel of deciduous native woodland and a number of mature Oak standards and an outlying Coastal Redwood commensurate to BS5837:2012 category A i.e. trees of high arboricultural quality (trees T1, T9, T13, T14, T20, T22, T24, T25, T19 and W2).
The Illustrative Masterplan shows how a development could be achieved that retains and promotes key trees and woodland as focal design features and uses retained hedgerow to enhance
connectivity between the site’s principal tree cover. The proposed access, development parcels and attenuation features have been sited to avoid important and protected tree loss and ensure that the connectivity between field boundaries can be maintained. Accordingly, the Masterplan demonstrates that the site has the capacity to receive residential development whilst safeguarding all of its significant arboricultural interests. A well-designed layout, it is considered, also has the capacity to capitalise on opportunities to increase biodiversity and visual amenity through new tree planting.

Agricultural Land Classification
MOH’s land has been awarded a score of 1 on agricultural land classification. The SAP explains that this
score has been awarded to all sites where the majority of the site contains Grade 1-3 agricultural land – in the case of MOH’s land it comprises Grade 3 land.
It is accepted that the majority of Rochford District comprises Grade 3 agricultural land and that as a
result many sites lying outside the settlement boundaries have been awarded the same score.
However, it is the loss of the best and most versatile agricultural land that the NPPF seeks to minimise
i.e that falling in Classes 1, 2 and 3a. Natural England’s Agricultural Land Classification (ALC) mapping does not distinguish between Grade 3a and 3b and so it is unclear whether sites constitute best and most versatile land but as Grade 3b does not and 3a is at the lower end of the BMV scale, it seems odd to have ranked sites in this way and to have included Grade 3 sites alongside those comprising Grade 1 and 2 land.
In a more rural district like Rochford further growth will inevitably need to be accommodated on agricultural land and the Council’s proposed strategy in the emerging Local Plan will result in further loss of agricultural land. Given that the district’s more sustainable settlements, like Rayleigh, are surrounded by agricultural land it is inevitable that sustainable growth can only be achieved by the redevelopment of agricultural land. Efforts should nonetheless be on minimising the loss of the best
agricultural land, namely that falling in Grades 1 and 2.
Heritage – Built Assets
The SAP attributes a score of 1 to the site in relation to built heritage on the basis that the “development of the site will cause substantial, or less than substantial, harm to a built heritage asset(s) which may need to be avoided”. The assets in question are three listed buildings comprising Great Wheatley Farmhouse and two barns, all listed at Grade II on 14th October 1986, which are located to the south west of the site. It is recognised from the footnote that this does not necessarily
mean that the need to avoid harm precludes development, however it is considered that the High-Level Heritage Impact Assessment (HLHA) from which this scoring is drawn, has incorrectly identified the likely level of harm that would arise from the development of the site.
A note has been produced by Asset Heritage Consulting (Enclosure 8), which in response to the conclusions of the HLHA provides an assessment of the significance of the heritage assets at Great Wheatley Farm and considers any harm likely to arise to them from the development of the site. The results of this assessment have informed a new Illustrative Masterplan for the site.
As the note explains, there appears to be an inconsistency in the HLHA’s ‘scoring’ of the site so far as it identifies a probable Moderate Adverse effect while the explanatory text that accompanies it suggests the potential for mitigation to remove such impacts through ‘careful master planning,’ and in doing so more accurately reflects the definition given to a Minor Adverse effect. The consequence of this being that the site should have scored more highly in the SAP.
The site lies within the physical setting of the farm group. Although the site is no longer in the same
ownership as the farm, and is not farmed from there, there is a historical connection between the farm
and the land within the site. In the mid-20th century, comprehensive residential development in the area led to encroachments onto the land associated with the farm, but despite these changes to the wider context, the site still provides opportunities to appreciate the significance of the farm buildings as a group in their historical context.
In order to positively respond to these conclusions, the masterplan has been revised to remove built
development from the parts of the site that are most sensitive and to preserve what is important about the setting of the three listed buildings at Great Wheatley Farm in respect of the contribution it makes to their significance. The key changes are:
The omission of all proposed development from the southern part of the site. This could instead be turned into a community orchard with footpath through to Great Wheatley Road; a use that is compatible with the historical land use surrounding the farm, would preserve the experience of the farm group surrounded by undeveloped land in key views and act as an effective screen to any glimpsed views of new development from Great Wheatley Road.
• The retention of a swathe of open undeveloped land southwest of the ridge in the north-western part of the, which would serve as a ‘buffer’ of open space between the listed farm buildings and
the proposed development and ensure the retention of key views across open land towards the
listed farm buildings, particularly the East Barn, preserving a sense of the historical functional
connection between the farm buildings and the land within the site.
• The provision of a belt of open space and tree planting along the ridge through the site which will act as a natural screen and filter development on the north-east side of the ridge as well as providing a new field boundary which would give definition to the edge of development and provide an attractive point from which to enjoy the retained open views to the south-west.
It is considered that these mitigation measures positively address the concerns expressed in the HLHA
and demonstrate that built heritage constraints would not preclude the development of the site.

Transport Sustainability
Under Theme 10: Transport Sustainability, the SAP assesses the relative performance of sites on the basis of their ability to promote sustainable patterns of movement and discourage the use of the private
car. This includes criteria relating to walking, cycling, sustainable transport and highways with the
assessment being informed by thematic assessments from the current evidence base. While the SAP’s
scoring of the site in terms of bus distance, walking, distance to strategic road network and access is
welcomed, it is considered that in relation to access to bus services and train services it underscores the site.
An Accessibility Note (Enclosure 9) has been produced by MAC that provides an appraisal of the
accessibility of the site via a range of transport modes to facilities and services and responds to the scoring awarded to the site by the SAP.
As the Accessibility Note explains, the nearest bus stops are located on High Road and are served by 5
services providing a range of destinations and frequencies. In the case of Route number 1 this typically
provides a high frequency 4-6 bus services per hour Monday to Saturday operating via Rayleigh Railway
Station. It is clear that the site does benefit from good access by bus and the score afforded by the SAP
to the site under the heading of bus services is not reflective of this. As regards access to the train
station, this is located between 800m and 1.1km from the site and according to the assessment criteria in the SAP it should therefore have received a score of 4 rather than the 3 given.
The site scores highly in relation to Walking Infrastructure in the SAP and as the Illustrative Masterplan shows, the development of the site offers the opportunity to further enhance its’ sustainability by providing a network of pedestrian and cycle routes through the development that would link to existing connections and the adjoining residential areas in Great Wheatley, thereby providing greater accessibility to existing public transport services, the public rights of way network and local facilities and amenities.
It is evident that the site is located in a highly accessible location on the edge of the district’s most sustainable settlement with many facilities located within acceptable walking and/or cycle distances.
Such facilities include bus stops and the train station providing access to destinations further afield.
Together with the further enhancements that any future development would be able to bring, this would provide future residents with a viable alternative to reliance on the use of the private car.

Conclusion
Having regard to the above, there are no significant environmental, physical, or legal impediments
to the development of land to the north of Great Wheatley Road. The site is capable of accommodating a level of development that could contribute positively in the long term to the shaping of the urban edge of Rayleigh by creating an enduring and defensible Green Belt boundary.
Consistent with the provisions of the NPPF, boundaries would be redefined utilising physical and permanent features such as the woodland and tree belts with landscape buffers to define the new Green Belt edge. A suitable and substantial undeveloped ‘gap’ could be maintained between the redefined Green Belt edge and existing settlements, and the development of the site would therefore not result in coalescence. This would also ensure that the setting and separate characters of the settlements would be preserved. It is therefore considered that the removal of the site from Green
Belt would not significantly affect the characteristics of the surrounding Green Belt designation or compromise the purposes for including land within it.
Given this and its location on the edge of Rayleigh, the most sustainable of the district’s settlements where a good range of services and facilities are available to meet the needs of their communities and support substantial growth, the site represents an eminently suitable source of housing land capable of delivering sustainable new homes early in the plan period alongside supporting infrastructure. By providing new housing within easy reach of existing facilities and services by a choice of sustainable modes, its development would make a positive contribution to the
completeness of the settlement.